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Source: GIUFFRE_MAXWELL  •  Size: 294.2 KB  •  OCR Confidence: 94.3%
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Case 1:15-cv-07433-LAP Document 1332-15 Filed 01/08/24 Page 8 of 11 Nassau, 289 F.R.D. 54, 64 (E.D.N.Y. 2012). Indeed, “[iJ]t is presumptively unfair for courts to modify protective orders which assure confidentiality and upon which the parties have reasonably relied.” /d. (internal citations and quotations omitted); see also Medical Diagnostic Imaging, PLLC v. Carecore Nat., LLC, 2009 WL 2135294, at *4 (S.D.N.Y. 2009) (denying motion to modify protective order because parties and third parties have reasonably relied upon the terms of the protective order). As discussed in detail in this Court’s previous Order, “[t]he Protective Order provided confidentiality for information the parties determine would ‘improperly annoy, embarrass or oppress any party, witness or person providing discovery in this case.’” May 2, 2017 Order Denying Modification of Protective Order (DE 892) at 4 (quoting Protective Order). Further, “{t]his Court has, three times, found the issues presented in the action warrant a Protective Order, and has specifically expressed concern for its ongoing efficacy.” Jd. at 5. Moreover, the Protective Order (DE 62) does not allow non-parties, like Epstein, to challenge the confidentiality designations or the efficacy of the Order. The Protective Order only states that parties can object to the confidentiality designations: “A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the disputed information . . . it shall be the obligation the party designating the information as CONFIDENTIAL to file an appropriate motion requesting that the Court determine whether the disputed information should be subject to the terms of this Protective Order.” (DE 62 at ¥ 11, p. 4). This Court’s Protective Order does not allow for non-parties to challenge these designations and therefore this Motion to Intervene, filed by Epstein and Groff, both non-parties to this case, should be rejected.

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Filename Giuffre_Maxwell_Batch7_p00296.png
File Size 294.2 KB
OCR Confidence 94.3%
Has Readable Text Yes
Text Length 1,990 characters
Indexed 2026-02-04 12:48:31.464556